Dedicated Space at Commonwealth Games Constitutes a Permanent Establishment

This case note reviews the Authority for Advance Rulings’ decision in the Production Resource Group case that a dedicated space at the 2010 Delhi Commonwealth Games to provide lighting, sound, video and LED technology services constituted a permanent establishment in India, and the income arising therefrom was business profits sourced in India, taxable in accordance with article 7 of the India-Belgium tax treaty (1993).